Verbal consent must describe how assent is recorded
The requirementstatement
The flow must state how the consumer’s spoken agreement is captured and retained — recording, transcript, IVR log, or timestamped CRM entry.
- Severityseverity
- HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
- When it bitesphase
- Gates approvalapprovalGet this wrong and the brand or campaign is refused at registration.
- What is checkedobject
- campaign.message_flow
- Where it liveslayer
- Consent flowCONSENT_FLOW
- How Ekas settles itdetectability
- AI · formAI_FORM
- A semantic question about what you wrote: whether a description matches a use case, whether a name looks like a filed entity. Judged by a model against written criteria.
- What the fix involvesfailureClass
- Fix the fieldRETRY_FIELD
- A better value in the form fixes it. Ekas can rewrite it and re-check.
- Who requires itauthorities
- FCCCTIATCR
- When it appliesapplicabilityText
- Applies when consent was collected by live verbal and IVR.
Why this rule existsrationale
Spoken consent evaporates unless it is written down. If a complaint arrives eighteen months later, the retained record is the only thing standing between you and an unprovable claim, and both the FCC and CTIA expect the record to exist.
How to fix itremediation
Add a sentence to the message flow describing capture and retention. Name the system of record and what is stored against the customer.
A compliant exampleexample
Calls are recorded, and the agent logs the consent timestamp, the script version read, and the number consented against the customer record in our CRM. Records are retained for at least 4 years.
Common mistakespitfalls
- Two-party consent states constrain call recording — where you cannot record, log the timestamp and script version instead.
Rules you will hit next
6 other rules read campaign.message_flow. Fixing one field to satisfy a single rule is how a resubmission trades one rejection for another, so read these before you change anything.
CMP-003Message flow must not begin or end with whitespaceBlockingBLOCKINGCMP-059Message flow must describe the mechanism end to endBlockingBLOCKINGCMP-060Every opt-in method in use must be listed in the message flowBlockingBLOCKINGCMP-061Each declared method needs its own complete workflow paragraphBlockingBLOCKINGCMP-072Message flow must state the message typesBlockingBLOCKINGCMP-073Message flow must state message frequencyBlockingBLOCKING
CON-VERBAL-RECORD is one of 101 consent flow rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.